1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

The purport of the claim and the appeal.

In the judgment of the court of first instance, the contents asserted by the Plaintiff after the judgment of the court of first instance to this court are not significantly different from the allegations in the judgment of first instance, except for the following portions to be determined additionally. Examining the evidence duly adopted and examined by the court of first instance, it is acceptable to acknowledge and determine the facts of the court of first instance as justifiable.

Therefore, this court's reasoning is that "18% (2018)" of the first instance judgment was dismissed as "16% (2018)" of the act No. 19 of the first instance judgment, and it is identical to the reasoning of the first instance judgment, except for the judgment as to the Plaintiff's additional assertion as stated in the second instance judgment, as it is stated in Article 8 (2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act.

In addition, the tax authorities, including the Plaintiff’s Director of the Customs Valuation Classification Division, the Customs Product Classification Committee, and the Defendant, expressed a public view that the Plaintiff, a taxpayer, is the subject of trust on the following terms: “The Plaintiff’s freezing of freezing from the Plaintiff falls under No. 0307.43-2010 of the tariff integrated tariff item classification table (hereinafter referred to as the “Items No. 0307.43-2010”).

Recognizing the above expression of opinion, the Plaintiff filed an import declaration of the Plaintiff’s frozen king of the Plaintiff’s import in accordance with the said expression of opinion, and paid customs duties by applying 22%, which is the adjusted tax rate in accordance with the Customs Act.

By expressing the error of the taxation authority's erroneous opinion and thereafter, the Commissioner of the Korea Customs Service made a public notice that the Plaintiff's freezing of the Plaintiff's import changed the item number from "No. 0307.43-2010 to "No. 0307.43-2090" (hereinafter "the amendment notice of this case") to "No. 0307.43-2090, the Plaintiff may pay customs duties in accordance with the tariff rate of 16% or 17% under the Act on Special Cases of the Customs Act for the Implementation of Free Trade Agreements if the Plaintiff's freezing of the import falls under No. 0307.43-2090.